to date : 10/11/2018 the director industry-2 · to date : 10/11/2018 the director industry-2...

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To Date : 10/11/2018 The director Industry-2 Ministry of Environment, Forest and Climate Change Indira Paryavaran Bhawan Subject: Reply of EDS dated 07-11-2018 for UPL-1 Ref: proposal no IA/GJ/IND2/80387/2017 and file no IA-J-11011/582/2017-IA- II(I) Dear Sir Please find the point wise reply of the EDS generated on 28-10-2018 Sl. no EDS Reply Reference attached 1 Please submit complete set of the CCR dated 16/10/2018 (only data sheet available on the portal) for further consideration of the proposal. CCR is attached herewith as annexure-1 Annexure-1 Thanking you Regards (Authorized Signatory)

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To Date : 10/11/2018 The director Industry-2 Ministry of Environment, Forest and Climate Change Indira Paryavaran Bhawan Subject: Reply of EDS dated 07-11-2018 for UPL-1 Ref: proposal no IA/GJ/IND2/80387/2017 and file no IA-J-11011/582/2017-IA-

II(I) Dear Sir Please find the point wise reply of the EDS generated on 28-10-2018

Sl. no

EDS Reply Reference attached

1 Please submit complete set of the CCR dated 16/10/2018 (only data sheet available on the portal) for further consideration of the proposal.

CCR is attached herewith as annexure-1

Annexure-1

Thanking you Regards

(Authorized Signatory)

STI{IT ITGF'RGOVERNMENT OF INDIA

qfr, To,

qrrd-q d B-q-tff d q-qiq-{ufi=q EM'T t cr-gqfrti wqq sqq-q qrdT d d ftdqTTnTq 31-1ftffrif, 17.07.2003 q 04.04. \Tq ggr'Tfdrq o-q ifr--a ti

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Dated: lB/foJ"fod

Shri Gyanesh Bharti ,

The Joint Secretary,

Indira P ary av ar an B hawan,Jorbagh Road, Aliganj,NewDelhi - 110003

qqiT{"T, qq W qdqrg qMq q't-d-q, Ministry of Environment, Forest and Climate Change

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MINISTRY OF EI\IVIRONMENT, FOREST &CLIMATE CHANGE

File No: s-s/2007(ENY4 5 6+* fl-isr rlrfr,sgffi Hfuq,

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frqq: M Wr{e-s sffi{fl ft ({fuc I) am, ffig+q, fuar rm-q, Iirit-d t ftenr ole-qTeTo9o-r$ d frwR d ft\ qqf-qi"tfq ffi d .{.iq frr

Sub. Expansion of Pesticide unit by IWs United Phosphorus Ltd. - Unit-I at Ankleshwar in DistrictBharuch, Gujarat reg environmental clearance.

Ref: 1. Ministry's letter no J-l l0l1/1 1712002-IA II (I) dated 17.07.20032. Ministry's letter no J-110111407/2006-14 II (l) dated 04.04.2007

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SPEED POSTql*q q-rqicq, qRqq qld,

Regional Office, Western Region,sErq qqFRut qq;l

"Kendriya Paryavaran Bhavan"16q € .io-eZink Road No. 3

p-5, 1frqis-{ c'rvRavi Shankar Nagar,*frqre (coso)/Bhopal-4620 1 6 (M.P.)

Telefax: 0755-2465054E-mail : rowz.bpl-mef@nic. in

Cont 2

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qfrftTR:

t- * gfl.d. .frqmq, ffi{o. '{', qqf{wT, oq G qilqTg qffi{ dTffiq, €F{iT qqfqwr q-fi,qiq qiq ts, €i-tr-s, r€ ffi - 110003 of fri qrflsf i-g t

Shri S.K. Srivastava, Scientist 'E', Ministry of Environment, Forest and Climate Change

Indira Paryavaran Bhawan, Jorbagh Road, Aliganj, NewDelhi-l10003 for kind informationplease.

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Dr. Sudheer Chintalapati, Scientist 'D', Monitoring Cell, Ministry of Environment, Forest and

Climate Change Indira Paryavaran Bhawan, Jorbagh Road, Aliganj, New Delhi- 110003

for kind information please.

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117 / 1rs, frGTI-tSS, fuf,r rsq, si6driR- 3e3 oo2, lwTd a1 frt q"-iTsf fu t

Shri S. M. Karhale,.General Manager (Environment), IWs United Phosphorous Ltd. (Unit-f,Plot No. ll7llI8, G.LD.C., Dist. Bharuch, Ankleshwar- 393 002, Gujarat for kindinformation please.

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Monitoring the lmplementation of Environment SafeguardsMinistry of Environment, Forest & Climate Change

Regional Office (W) BhopalMONITORING REPORT

DATA SHEET

Sr.No

Particulars Reply

01 Project type : River VatleylMining/Industry/Therma[/ Nuclear/Other(Specify)

INDUSTRY (Expansion of Pesticide Unit at existingsite)

02 Name of the project Expansion of Pesticide unit by M/s United PhosphorusLtd. Unit-l at Ankteshwar in District Bharuch.Gujarat reg environmental ctearance.

03 Clearance tetter (s)/OM no. and dateo Environmental Clearance No. J-1101 11117 /2002-lA

ll dated 17th Juty, 2003 for various products;

04 Location

A District Bharuch

B State Gujarat

c Location (tatitude / tongitude) Latitude: 21"25'45"NLongitude: 72" 34'Lg"E at ELE - 38.25 meter heisht.

05 Address for correspondence

A Address of concerned ChiefEngineer (with Pin Code & Mob No/Telephone / Telefax / Emait)

Mr Anit C Mundada

UPL Limited, Unit # 01

Ptot # '117 &. 118, Notified Industriat Estate, GIDC,Ankteshwar, Ta.- Ankleshwar, Dist.- Bharuch,Gujarat- 393001, India.

Phone #02646-251223

Emai[ : [email protected]

mundadaac@uniphos. com

B Address of Concerned ProjectEngineer (with Pin Code & Mob No/Telephone / Telefax / Emait)

Dr Sunit Waje

UPL Limited, Unit # 01

Ptot # 117 &. 118, Notified Industrial Estate, GIDC,Ankleshwar, Ta.- Ankleshwar, Dist.- Bharuch,Gujarat- 393001, India.

Phone #0264'6-251223

Emai[ : [email protected]

[email protected]

06 Satient features

A of the Project o Continuous futty automated DCS/pLC basedsystem.

o Power suppty from DGVCL. No power qeneration

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5r.No

Particulars plv

by usage ot conventronal tuet.Natural gas based medium capacity boilers forsteam generation.Energy efficient instattations at different plants.Water Source: Onty GIDC Supptied, No Groundwater.Paved Areas for circulation and covered storagesfor handting of raw materiats and finishedproducts.Connectivity: Located near NH - 8 having highconnectivity and good approach to site.Expansions within site & maximum utitization ofexisting facilities.Provision of Canteen, Bath & Change room facitityfor atl workmen.Treated efftuent is sent to Final EfftuentTreatment Ptant (FETP) operated by M/s NarmadaCtean Tech (NCT) for further treatment & deepsea disposal through closed pipetine system.ICC - Resoonsibte Care Certified Unit.

B Of the Environment ManagementPtan

Instatted RO Ptant with capacity of 125 KL/Day &Usage of RO permeate water in cooling tower.Installed Singte stage forced evaporation systemfor high COD/High TDS efftuent.Segregation of efftuent streams and treatment asper characteristics.Green Belt Development & lts maintenance.Utilization of canteen waste for making bio gas.

CSR activities at near by vittages.Recovery of Sotvent Methyt ChtorideRecovery of By Products DCP Studge, CaC[2,Ammonia, Sodium Sutphide.A 400 KLD Capacity Effluent Treatment plant withprimary, secondary & tertiary treatmentUsage of ctean fuel - Natural Gas.Instaltation of online monitoring system fortreated efftuent &' data are connected to ontineCPCB server.Instattation of scrubbers / bag filters for controlof particutate matter and gaseous emissions.Scheduted Monitoring of treated waste water,stack monitoring, work place monitoring andambient air quatity monitoring by internal andexternal agency.Estabtishment of Green Cetli EnvironmentManagement Cett.ISO 14001 Certification.

07 Break-up of the project area

A Submergence area - forest and non-forest

There is no forest area invotved in the project as theproject located within Notified GIDC area.

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Sr.No

Particulars Reply

B Others :Not Appticabte.

08 Break-up of the project affectedpopulation with enumeration of thoselosing house / dwetting units onlyagricultural land, both dwetting units andagricutturat [and; and landtess labours /artisan

A SC, ST / Adivasi Not Appticabte as project located within Notified'GIDC area.

B Others

09 Financia[ detaits

A Project cost as originatty revisedestimates and the year of pricereference.

Project planned cost: Rs. 12 CroreProject revised estimated cost: Rs. 13.77 Crores.

B Allocation made for EMP with item.wise and year-wise break-up

As per Annexure-1

c BC ratio / IRR and the year ofassessment (if appticabte)

17%in the year of 2011

D Whether (C) inctudes the cost ofEnvironment Management as shownin above

YES

E Actual expenditure incurred on theproject so far

Rs. 122.19 Crore (Capital Investments)

F Actua[ expenditure incurred on theEMP so far

Rs. 28.22 Crores (Capitat Investment) forlmplementation of EMP for atl products produced atsite tilt date. The break uo is eiven in Annexure 1.

10 Forest land requirement

A The status of approval for diversionof forest land for non-forestry use

The project is tocated within Notified IndustriatEstate - GIDC, hence No,forest tand invotvement forthe project.

B The status of cleaning fetting The project is located within Notified IndustrialEstate - GIDC, hence No forest land involvement forthe project.

c The status of CompensatoryAfforestation, if any

The project is located within..Notified Industria[Estate - GIDC, hence No forest land involvement forthe project.

D Comments on the viabitity &sustainabitity of compensatoryafforestation programme in thetight of actual fietd experience so

The project is located within Notified IndustriatEstate - GIDC, hence No forest land involvement forthe project.

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Sr.No

Particulars Reply

far

11 The status of ctear fetting in non-forestareas (such as submergence area orreservoir, approach roads) if any, withquantitative information

Not Appticabte as project located within NotifiedGIDC area.

12 Status of construction

A Date of commencement (actuat and/ or ptanned)

As per Annexure-2.

B Date of completion (actual and / orplanned)

13 Reason for detay if the project is yet tostart

Not Appticabte

14 Detaits of site visit

A The dates on which the project wasmonitored previous occasions. (lfappticabte)by the MoEF&CC,Regiona[ Office on

26t01t2006

B Date of the site visit for the presentmonitonng report (if undertaken)

18.07.2018

15 Details of,correspondence with project authorities for obtaining act on plms/ informationon status of compliance to safeguards other than the routine letters for logistic support forsite visits. (The first monitoring report may contain the details of all the letters issued so

far, but the later reports may cover only the letter issued subsequently)

Date Letter from RO Date Letter from PA

10.04.20L8: MoEF&CC, RO Bhopal letter no. 5-

5/2007 / (Env)/033 dated 10.04.201807.05.2018: PP had submitted compliance reportvide letter dated 28.04.2018 and received inMoEF&CC, RO Bhopal on 07.05.2018

l8.O7.20l8z During the site visit, PP has beendirected to submit the revised ComprehensiveCR.

25.09.20L8: PP had submitted updated halfyearly compliance report vide letter dated19.09.2078 and received in MoEF&CC, ROBhopal on 25.09.2018

08.10.20L8: Additional clarification sought w.r.t.water consumption and hazardous wastegeneration vide e-mail dated 08.10.2018

11.10.2018: Reply submitted by PP vide e-maildated 11.10.2018

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Annexure-1

5r.

No.PIont

Pollution ControlMeasures

EMS Copex

Cost in INR(Crore)

O&MCostinINR (Crore)(2015-16)

O&MCostinINR (Crore)(2076-17)

O&MCostinlNfl(Crore)

P017-$)

L

Mancozeb,Maneb, Zineb,

Ziram

Cyclone & Scrubber(old & New)

4.00 0.0s 0.0s 0.05

2 AntracolCyclone & Bag

Filter1.00 0.16 0.16 0.15

3 Flonicamide (lKl) Water Scrubber &Caustic Scrubber

6.7L 0.4665 0,3611 0.3866

4TriMethyl

Phosphite / TriEthyl Phosphite

Process Scrubber 0,43 0.039 0.037 0.037

5 Solid Formulation Bag Filter, Scrubber L.45 0.0600 0.0804 0.0657

6 Storage Tank PCl3 Alkali Scrubber 0.24 0.1277 0.0907 0.2110

7 Calcium ChlorideCyclone & Water

Scrubber1.5 0.1684 0.1656 0.1586

8ETP & WasteManagement

Primary, Secondary& Tertiary

Treatment & WasteDisposal

208 8.2589 9.2205 11.5388

9 Green Belt Cost Plantation, Nursery 0 0.297 0.2018 0.292

10

EnvironmentManagement Cell

Cost

Compliance &Monitoring

0 1.4152 1.6166 1.5301

11Methyl Chloride

RecoveryResource Recovery 5.21

Included inETP & WasteManagementCost

Included in

ETP & WasteManagementCost

Included inETP & WasteManagementCost

t2General

Environmentlmprovements

Energy

Conservation, GHK

& Monitoring5.60

TOTAL 28.22 11.04 11.98 L4.42

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Annexure-2

Sr; No Name of Product Month / Year ofcommencement of work

Month / Year ofComoletion bf work

1 Mancozeb Juty - 2003 Juty-2004

2 Antracol Juty - 2003 August - 2005

3 Dichlorovos Juty - 2003 January - 2006

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Part-II&III

DESCRIPTIVE REPORT ON STATUS OF COMPLIANCE TO CONDITIONS OF ENVIRONMENT CLEARANCE ANDENVIRONMENT MANAGEMENT'

Compliance Status (for the period of Jan-2018-June-2018)of Environmental Clearance issued by MoEF,New Delhi Environment Clearance Reference no letter. no. J-tLol:/fl7/2o02-tl l (t) dated L7lo7l2oa3 &t-rLoLll4O7l2005-tA il (t) dated 04.04.2007

(Detai! of pnoject: Pesticide manufacturing uqit by M/s United Phosphorus Ltd. - Unit-l atAnkleshwar in District Bharuch, Gujarat.)

Condition Compliance StatusNo Description

*The Environmental Clearance is issuedfor the following products+ Penoxaline @ 150 MT/ Month

= Cartap @ 50 MT/ Month

= Metabromuron @ 50 MT/ Month

= Phosphamidon @ 150 MT/ Month

= Dichlorovos @ 200 MT / Month;and

= Antracol / Mancozeb @ 500/300MT/ Month

Project Proponent vide letter dated 19.09.2018received in MOEF&CC, RO Bhopal on 25.09.2018submitted the fol lowing:Complied.The unit has

Penoxa line,discontinued production of

Ca rta p,

Metabromuron&Phosphamidon. The Unit has

taken product mix changes for products given inEnvironmental Clearance and Now, The Unitproduces the pesticide products as per latestConsent granted by GPCB. The details of ProductMix Change from EC to CTE/CTO are given as

Annexure 1A in the main report.The revised production capacities as per vide GPCB

CC&A # 88493 dated 26.O9.2Ot7 valid up toL2.O5.2018. is tabulated below:

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Compliance Status

*AllQuontities ore wellwithin GPCB Consented Limits

The unit has discontinued production of Penoxaline,

Cartap, Metabromuron&Phosphamidon, The by-

product quantity and type has been changed as per

change in product mix. Now, The Unit produces the

pesticide products as per latest Consent granted by

GPCB & Generates by products as per latest consent

granted by GPCB. The details of Product Mix Change

with By Products from EC to CTE/CTO are given as

Annexure 1A in the main rePort.

Complied.The revised by-product capacities as per vide GPCB

CC&A # 88493 dated 26.09.2017 valid up to 12.05.2018.

is tabulated below:

Environmental Clearance also contains

the following by-products:+ Hydrated Sodium Sulphate @ 737

MT / Month+ Sodium Sulphite Solution @ 298 MT

/ Month+ Sodium Bromide Solution @ 95 MT

/ Month

= Sodium Sulphate Solids @ 31 MT /Month

+ Liquefied Methyl Chloride @ L31'

MT / Month30 % HCL @ 138 MT / Month

60(Combined

Capacity)

Sulfos u lf u ra n

Sodium Sulphate

Sodium Sulphate

Sodium Bi sulpite

Calcium ChlorideSolid Fused/

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Compliance Status

ihu unit has obtained CCA amendment for product mixchange. Presently, unit is operated as per GpCB

Consent to Operate (CC&A) renewed with amendmentfor existing products and new solid & liquid formulationproducts; vide GPCB CC&A # 88493 dated 26.09,2017valid up to 12.05.2018.

The Unit has applied to GPCB for Renewal of Consentvide letter no U1lCC & A R&A/18 dated March 30,2018.(The copy of valid CC& A is attached as Annexure-1 B inthe main report & Copy of application for consentrenewal submission acknowledgement is from GpCB is

attached as Annexure 1 C in the main report).The Monthly Production details are attached as

Annexure 2 in the main report for the period ofJanuary 2018 to June 2018.

PP submitted that Environmental Clearance #t.Lrc1'J./40712006-tA.|(tl dated o4.o4.2oo7granted to Unit # 1 was for product mix changeand the same was not implemented and notobtained NOC (CTE). However, as per the detailsfurnished by the PP, several product mix changeshave been made over the years w.r.t.Environmental Clearance # !.tL0Ltl77 IZOO2-lA.tldated L7.07.2003 in accordance with theguidelines available under EIA notification 2004w.r.t. product mix change under no increase inpollution load with prior permission from GpCB.The said product mix changes are valid w.r.t. EIAnotification OM dated 28.LL.2OL6 related toproduct mix change and as the pp has intimatedthe said changes regularly in the form of Six-monthly compliance reports, Ministry may takean appropriate view on the applicability of saidOM retrospectively taking into consideration thedynamics of the pesticide sector. In view of theabove, the stipulated para is considered compliedsubject to acceptance by MoEFCC, New Delhi.COMPLIED SUBJECT TO ACCEPTANCE BY MOEFCC,

Sodium Sulohite

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Compliance Status

19.09.2018 received in

MOEF&CC, RO Bhopal on 25'09'2018 submitted the following:

Complied.The fand area of the project is!,36'677 m2 and does not involve forest

landanddisp|acementofpeopleastheunitislocatedwithinNotifiedrndustriar Estate, GrDc, Ankreir,*.r. The copy of land allotment letter

infavorofUPLUnitl.isattachedasAnnexure03inthemainreport.

ln view of the information furnished by the PP' the stipulated

condition is considered complied'

The land area of the

project is !, 36,677 m''Project does not involve

forest land and

displacement of PeoPle'

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Water requirement9s1.1 kl / day.

The unit has taken permission for pproducts along with technical grade pesticide products whichconsumes minor quantity of additional water. Hence total waterrequirement for unit is 1039 KL/Day as per GpcB consent order no H-88493. The daily water consumption for last six months has been givenas Annexure 04 in the main report. The copy of valid CC & A isattached as Annexure-l B in the main report.The daily water consumption details are summarized in the followingtable below in the main reoort:marn

MonthWater

Consumption inKLD

Water Consumption inKLlMonth

GPCB timit 1039 KrD 32209 K[/MonthJan 2018 629.87 19526Feb 2018 734.54 20s67Mar 2018 9ss,58 29626Apr 2018 988.57 296s7May 2018 1037.10 32150Jun 20L8 1036.93 31108

ln reply to a clorificotion sought vide e-mail doted 0g.i.0.20i.g, pp vide e-moil dated 1-1.L0.2018 submitted the foltowing:o Fresh water consumption os per Environmental cleqrance dqted 17.02.2003

is 951 KLD,

o we hove opplied to GpcB for crE / uoc for sorid / riquid pesticideformulotion products on 17/10/2012 for which EC is not oppricabre.

' GPCB hos given permission and these products were included in our cc &A" cc & A No AWH - 55992 dated 31.07.2013.

o Accordingly fresh wqter consumption has increosed by gg KLD i.e. totot (g51+ 88) 1039 KLD.

' GPCB has issued cc &ANo AWH - 55992 doted31,07.2013 giving the detoilsof woter consumption.

quantities.In view of the information furnis e stipulated condition isconsidered complied subject to ac suing authority.COMPLIED SUBJECT TO BY EC ISSUINGAUTHORITY

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Product mix change,

itY of hazardotis waste-+ (^-

has been changed. Please refer Annexure 1A in the main report for

revised quantities of hazardous waste from EC To Till date as per latest

CC&ANoH-88493' -^!-tL-The waste disposal quantities are attached as Annexure 18 in the main

report.

Thewastedisposa|quantityissummarizedinfo||owingtab|ebe|ow:

DISPOSAL

(TotalSent to

BEIL)

WSolidwaste

ClosingStock

MONTHOp.

Stock

GENERATION in MT/Month

ETP

Sludge

Salt (lnorganic

solids fromMonocrotoPhos

Plant/RO)

TotalQuantitY

Sent toBEIL

r IIAll Lluanllrles lIr rYr I

r

ZOO.UU!on'78 5q.II 4L 192 233.0u

tgt.44 224.2t ,L24.55

22109

0.99

2.03

2.03

Feb'78 111 32.1 t

March'78 099 32.48 193.65 1ZO. L5

Aor'78 703 39 00 190.00 229.00 229.00

Moy'78 203 4L.04 194.55 237.62 235.59

2.03 415 1q5 238.48 zzo.)u 11.98

Totol 227.79 1156.54

GPCB PermissibleLimit

{MT/ six Months)

2s0 tLTt

ililililililililililililililililo|'rd waste in the form of

o ETP Sludge (30 MT /Month);

o lncinerator Ash (4'5

MT / Month) and

o lnorganic Solids from

MonocrotoPnosPlant (75.6 MT IMonth);

o Solid Salts (82 MT /Month); and

o Salt from RO SYstem

will be disPosed off in the

secured landfill facilitY'

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D D WASTE I.ANTOTAL LANDFILt WASTE DETATLS -All Quantities are in MT/Month

MONTH(ETP

SLUDGE +

sALT)*

DCP

SLUDGE**

NON-RECYCLABLE

PLASTIC

WASTE/INSULATIONWASTE

TOTAL

Jan'78 266 L t:t). )at 27.22 1488.80Feb'18 224.33 283.03 L6.40 523.76

Morch'78 225.09 569.79 26.06 820,94Apr'18 zzJ 442.39 23.75 695.14Mav'78 235.59 440.9L 22.09 698.s9lune'18 226.50 367.89 26.02 620.41

Total 1406.51 3299.s9 L4L,54GPCB Permissible

Limit(MT/ Six Months)

t42t 7200 352.5

*All Quantities ore well within GPCB Consented Limits

DETATLS OF DCp SLUDGE (BY-PRODUCT / SOLD AS SOtL CONDTTTONER & BEtL)

MT/Month - Non Hazardous Waste

MONTHOPENING

STOCK

(MT)

GENERATION

(MT)

DTSPATCH (MT) ClosingStock

PARW+ BEI L

Jan'78 689.06 1-195 325.0s L 195.58 5bJ.4JFeb'18 363.43 1ZZ 0 283.03 502.40

March'78 502.40 82s 181.85 569.79 575.76

Apr'18 569.79 5L0 3t6.2 442.39 321,.20Mav'78 32L.20 677.t2 437.7s 440.91, -t Lv.ooJune'78 119.65 640 0 367.89 39r.77

Totol 4269.12 1260.85 3299.59GPCB Permissible Limit - 7200 MT/Six Months

(*) sold as soil conditioner to end user: G B AGRO Industries, plot no L723,GIDC, Panoli, Ankleshwar - 394LI6.ln reply to o clarificotion sought vide e-moil doted 0g.10.20J.9, pp vide e-moil doted 11.1.0.20L8 submitted o detailed note on the reosons forenhanced solid woste generation, the detoits of which is enclosed asAnnexure-AA enclosed at the end of the report:

In view of the information furnished by the pp and subsequentclarification furnished by the pp w,r.t. enhanced pollution load dueto formulation unit and other technological .changes in effluentdisposal, the stipulated condition is considered complied subject toacceptance by EC issuing authority.COMPLIED SUBJECT TO ACCEPTANCE BY EC ISSUING AUTHORITY

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erolect Proponent vide letter dated 19.09.2O18 received in MOEF&CC, RO BhoPal on

25.09.2018 submitted the following:

ffittached as Annexure 1D in the main

report.

ln view of the information furnished by the PP' the stipulated

condition is considered complied'

COMPLIED

NOC from GPCB was

obtained on 29.06.2002'

the PP' the stiPulated

ftoched as Annexure 5 A in the

main report and action plan with complionce stotus is attoched

A 58 in the main summortze

Sr. No No of lssues raised No of Action Point ComPlied

L 15 If

Public Hearing was held

on 16.0L.2002

spectrtc coNDlrloNS )Crt.ort emissions (SO2, NOx, HCl, HC

and Clz) and PM from various process

units should conform to standards

prescribed by authorities. At no time,

emissions to go beYond standards'

Project ProPonent vide letter

MOEF&CC, RO BhoPal on

following:

dated 19.09'2018 received in

25.09,2018 submitted the

Complied. -- _..11^--The unit has installed Bag Filters, Water Scrubbers' Caustic Scrubbers'

Acid Scrubbers & Cyclones for control of Gaseous emission like HCI' SO2'

NH3, Clz and Particulate Matter (PM) which conform to prescribed

standards by GPCB. The details of flue stacks & process stacks with

scrubbers is given in Annexure g in the main report' The Hydrocarbon

measurement has been covered under VOC Monitoring' The copy of VOC

Monitoring at different plant areas has been attached as Annexure 10 In

themainreport.TheStackMonitoringisdoneinterna||yandthroughNABL Accredited Laboratory - Bharuch Enviro Infrastructure Ltd (BEIL)'

The third-party analysis range as follows in a table below'Measurement Result

Range in mg/nM3(ExcePt SO2 & NOx)

Jan 18 To June 18Pollutant / Source

ir Generator Stack/ CaCl2 Plant

Stack)

150 mg/nM3Particulate Matter :

Boiler 1/2 &3, Hot Air

Generator, CaCl2 Plant

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Condition Compliance StatusNo. Description

2

Sulphur Dioxide (SO2)

Boiler t/2 &3, Hot AirGenerator

100 ppm 3.8 ppm28.3ppm

3

Oxides of Nitrogen (NOx)

- Boiler tl2 &3, Hot AirGenerator

50 ppm 8,4 ppm20,7ppm

Process Emissions - Pesticide T echnical / Intermediate /Formulation

7

Particulate Matter -

Ma ncozeb/Ma neb/Zineb

/Ziram/Antracol(Technical Pesticide) &

Formulation

20 mglnM3 2.5 19

2HCI -Flonicamide(lKl)Plant Caustic Scrubber

20 mg/nM3 BDL BDL

Chlorine - TMP Plant 09 mslnM' BDL 195 Ammonia - TMP Plant 175 me/nM' BDL 49.3

6SO2 - Flonicamide(lKl)

Plant - Caustic Scrubber40 mg/nM3 BDL BDL

7

Ammonia -

Flonicamide(lKl) PlantWater Scrubber

30 mglnvl BDL 73

Other Plant Emissions - Non Pesticide Process

1 HCI - PCl. Storaee Tank 20 mg/nM" BDL 131L Cl2 - PCL" Storase Tank 9 melnM' BDL 08

The ln

Eil,l

:

:

i_lProrIl,l

: rl

ternal Lab analysis range as

-'Gas Stacks (Boiler Stacks &

:ess Emissions - Pesticide Tr

follows in a table below.

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Ammonia - TMP Plant

SO2 - Flonicamide(lKl)

Ammonia -

Flonicamide(lKl)Plant -

Water Scrubber

other Plant Emissions - Ng! P"ry,ejrolgtt

HCI - PCl3 Storage Tank

Cl2 - PCL3 Storage Tank

The Ambient Air Quality Monitoring conducted by internal and external

agency is enclosed as Annexure - z in the main report& analysis range

is as follows done by ISO 14001 Certified & NABL Accredited

riod of JanuarY 2018 to June

2018 as Annexure e in the main report'

kleshwar)

The analYsis range of Ambient Air Quality Monitortng conducted

internal laboratory is gi as follows: -

Labora M/s BEIL, An

5rNo

MajorParameters

Norms / Limit(Fc /m3)

Monitoring resulr range

(in uel m3)Jan 18 To June 18

Minimum Maximum

AMBIENI AIR QUALITY MO NITORING - Pgl m3

L PM to 1.00 4t.7 69.5

2 PM 60 22.3 39.7

SOx 80 19.5 24.7

4 NOx 80 L7.4 lo,3

5 HCI 200 BDL BDL

6 NH3 400 BDL 60

H2S 500 BDL BDL

8 HC 160 BDL BDL

9 a^ 100 BDL BDL

10 co 2000 BDL BDL

Monitoring result range

AMBIENT AIR QUALITY lvtoryLrpB!t\9:!c/ r:

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Compliance Status

During failure of pollution controlsystems, unit should not be restarteduntil measures are rectified to achievethe efficiency

The unit has implemented system for preparedness during failure ofpollution control systems by provision of automated system throughcentral control room. The production of product is not executed until thepollution control system is reestablished. The details of interlockingsystem implemented is attached as Annexure Zg in the main reoort.

In view of the information furnished by the pp and themonitoring results showing that all the parameters are wellwithin the stipulated norms, the stipulated condition isconsidered complied.COMPLIED

Fugitive emissions in workplaceenvironment, product, raw materialstorage areas must be monitored.

Project Proponent vide'letter dated 19.09,2018 received inMOEF&CC, RO Bhopal on 25.09.2018 submitted thefollowing:Complied.Fugitive emissionmaterial storage

analysis report is

monitoring at workplace environment, product, rawarea being carried out by QA Department. Detailed

enclosed in Annexure -8 A in the main reoort&anatysts range is as tollows tor workplace, product and raw-materials,

Sr

No

MajorParam

etersPlant /Area

TLV

(ppm)

Monitoring resultrange (ppm)

.!an 18 To June 18

Min MaxFugitive Emission

1 c2 MCP Plant UJ BDL BDL

z NH3 Ammonia Plant 25 r.z) 22

5 cs2 Mancozeb Plant 10 BDL 5

The External agency fugitive emission monitoripg at production, MaterialHandling, Finished Product Packaging areas is given below.

Monitoring resultrange (mg/M3)

Dec 2017

Fugitive Emission

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Compliance StatusCondition

trto. I DescriptionFloor/ l'

Floor/2no Floor

zTotalDust

Mancozeb

Plant Packing &

First Floor

10 7.2 88

I otalDust

Antracol Plant

Packaging & 1't

Floor

10 BDL BDL

4 NH3AmmoniaRecovery

BDL 13

5

6

7

H25Mancozeb

Liquid3.4 34

TMPTMP Plant First

Floor7.7 7.7

c2Chlorinestorage

BDL BDL

8 HC TMP Plant a.J

ffiits.The Analysis reports are attached

Annexure ee in the main report'

d5

Flu" gas emissions should conform to

standards Prescribed bY GPCB

Flue gas emissions are contormlng wlrn tne strPu

pr"r.rlb.d by GPCB in the unit and the details of the same are mentioned

in above compliance of condition no' L of Specific conditions and

Annexure - e in the main report'|nviewoftheinformationfurnishedbythePPandthemonitoring results showing that all the parameters well within

the stipulated norms, the stipulated condition is considered

complied.COMPLIED

p.j".t proponent v-'rde letter dated 19.09.2018 received in

MOEF&CC, RO Bhopal on 25'09'2018 submitted the

following:

mmarized belowahhoYrrra q in the main fePort & 5u

Stack Attached to Air pollution Control Device (APcD)

TMP Plant- NeutralizationProcess

HCI scrubber followed bY Water

Scrubber

Solid Formulation Plant Bag Filter & Wet Scrubber (HYPO)

M a ncozeb/M aneb lZineb /7iram Plant- Old SPraY DrYer

Cyclone & Water + Venturi Scrubber

PCl3 storage tank- Caustic

Scrubber (Packed column)Alkali Scrubber

Process emissions (SPM, HCl, SOz,

Methyl Chloride and VOC) should be

scrubbed through caustic venturi

scrubber and conform to standards'

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Condition Compliance StatusNo. Description

CaCl2 Plant- Spray Dryer Cyclone& Water + Venturi Scrubber

New Spray Drier ofMancozeb / Maneb /Zineb/Tiram

Cyclone & Water Scrubber

Antracol Spray Drier Bag FilterFlonicamide plant Ammoniagenerating reactor

Water scrubber (Packed column)

Flonicamide Plant at HCL andSO2 geperating reactor

Water Scrubber followed byCaustic(Packed columns)

Condition No l.fhe Unit measures VOCs in Fugitive emissions & Worrplace emissions, The detailed report of VOC Measurement is attached as

Annexure fO in the main report &summarized in EC ComplianceSpecific Condition No 2.The company has installed recovery plant forgenerated methyl chloride gas with closed handling system. RecoveredMeCl is sold as valuable by product. The recovery of Methyl chloride ismaintained @ 700%. The details of solvent recovery is given in

ln view of the information furnished by the pp, the stipulatedsub-condition is considered complied.Complied

Efficiency of scrubber to be improvedand maintained as per best practicabletechnology.

The efficiency of scrubber / bag filters has been improved with update intechnology. The details of efficiency of scrubber have been attached as

in the maiAnnexure 30 In tne matn feport & Summarized belowStack Attached To % Efficiency

CaCl2 Plant - Spray Drier with water scrubber 99.95Solid Formulation - Bag Filter 99.98Spray Drier with wet scrubber at Mancozeb /Maneb/Tineb/Ziram (NEW & Old)

99.99

TMP Plant - Water Scrubber 99.99

PCL 3 Plant Caustic Scrubber 99.99

Flonicamide (lKl) Plant Water Scrubber 99.99

Flonicamide (lKl) Plant Caustic Scrubber 99.99

In view of the information furnishedsub-condition is considered complied.Complied

by the PP, the stipulated

VOC data to be monitored andsubmitted to MoEF.

The VOC data are regularly monitored by pHOTOVAC VOC Monitoringequipment and monitored data has been submitted to MoEF along withHalf Yearly Compliance Report. The copy of VOC Monitoring reports atdifferent location has been attached as Annexure fO in the mainreport &In view of the information furnished by the pp, the stipulatedsub-condition is considered complied.

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Mancozeb Plant. The

production of products Penoxa li ne' Ii :tpht *d:l^ t:l

:::^tff *:::iJffi:;'rla ,"n,'"""0 from GpcB consent. rhe phor.6raph showing

additionar scrubber instatied arong with existing scrubber is attached as

Annexure r1 in the main rePort'

ln view of the information furnished by the PP' the stipulated

sub-condition is considered complied'

Complied

aan'tntt uentrti scrubber for

Mancozeb, Penoxaline, Phosphamidon

olant and a scrubber for Cartap plant

to be installed in addition to process

scrubbers already installed in the unit

each of the sub-

conditions, the overall compliance of the stipulated condition is

considered comPlied.

COMPLIED

following:Complied.The pesticide proclucts are always in seasonal demand and generates

effluent in peak demand' The ed NOC No:

,)ityr-ooit-Jrt.d zg'o Julv 200 apacitv of 423

for product quantity granted EC elhi' The copy

attached as Annexure fO in the ort' The EIA

95 KL/Day is based on actual generation of waste water only'

ng CC & A of GPCB H 88493 dated 2610912017 the treated

discharge quantity is 423't KL/Day

TheUnithasinsta||edeffluenttreatmentplantwith450KLDcapacityfacilitated with primary, secondary & tertiary treatment levels'Treated

effluent is discharged to Notified GIDC drain to final Effluent treatment

po*nw',d. fttt"' Otttd 19'09'20L8 received in

MOEF&CC, RO Bhopal on 25'09'2018 submitted the

plant operated (FETP) by NCT, Ankleshwar for further treatment &

;i;;"tti to deep sea through pipeline' Details of quantity discharged are

attached herewith as Annexure 12A in the main report and the

summarized details of quantity of treated effluent discharge to NCT is

tabulated as below:

Rs reftecteO in EIA / EMP Report'

effluent generation should not exceed

195 m3 / dav.

Quantity of Treated

Effluent Discharged in

KL/Month

Quantity of Treated

Effluent Discharged

JanuarY 2018

March 2018

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Condition Compliance StatusNo Description

The waste streams to be segregatedinto high and low pollution loadstrea ms.

lKLp ltn view of the i

effluent quantity stipulated in EC is much lower than the actualgeneration, the stipulated sub-condition is considered notcomplied.Not complied

The company has implemented stream wise proper segregation asfollows.

Sr.

No

Strea m Cha racteristics Treatment Quantity inKLD (2017-18)

1 Toxic and Orqanic Incineration 3.442 Hieh TDS & Low COD Eva poratio n 28.163 High COD Pre-Treatment

followed by ETPI44.3

4 Bio Degradable Effluent(Low COD/Low TDS)

To EffluentTreatment Plant

r79.4

ln view of the information furnished by the pp, the stipulatedsub-condition is considered complied.Complied

Effluent with high organic load to beincinerated and dilute streams likefrom R & D, washing, domestic, dilutestreams from process and scrubberblow down, to be given primary,secondary and tertiary treatmentbefore discharging into GIDC drain.

Treated effluent to conformsta nd ards.

The effluent with high organic load has been sent for incineration at BEI_.The summarized details of effluent quantity sent to BEIL is given below.

ln view of the information furnished by the pp, the stipulatedsub-condition is considered complied.Complied

DETAILs OF INCINERABLE WASTE - MT / Month

MONTHOPENING

STOCK

(MT)

GENERATION DISPOSAL

(Total

Sent toBEt L)

CLOSING

STOCKORGANIC&

AQUEOUS

tan'18 3t.45 79.6 LA2,]T L4.34Feb'18 1,4.34 33.36 33.36 1.4.34

Mqr'78 14.34 80.5 76.81 18.03Apr'78 18.03 749.I 123.79 43.94May'78 43.94 287 218.35 52.59Jun'78 52.59 2r0 237.54 25.0s

Total 839.55 851.95GPCB Permissible Limit

(MT/ Six Months) 978

The dilute streams from R & D, Washing, domestic, dilute streams fromprocess scrubber blow down is given primary, secondary & tertiarytreatment before discharge to GICD Drain. The treatment scheme &details of ETP are attached as Annexure t2 B in the main report.

The treated effluent is confirms to standards stipulated by GpCB in CC &A. The daily analysis report of effluent is given as Annexure ff in the

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Compliance Status

main rePort & summarized below'

5.5 to 8.5

Chemical OxYgen

Demand10mg/lOil and Grease

50mg/l

0.1mg/lHexavalentChromium

Total Chromium

0.01 mg / |

0.2me /l0.05 mg / |

90 % survival of

fish after 96 hrs in

100 % effluent

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Condition Compliance StatusNo. Description

ln view of the information furnished by the PP and themonitoring results showing that all the parameters well withinthe stipulated norms, the stipulated sub-condition is consideredcomplied.Complied

Nontoxic effluent to be diverted to RO

plant and re-cycled to minimize freshwater consumption.

Unit has installed water recycling system (R.O Plant) @ 100 KL/Day"Permeate from RO (Reverse Osmosis) System is taken to cooling towerwater make up. The quantity of RO Permeate month wise details

attached in Annexure -fq in the main report and the summarizeodetailsof permeate generation from water recycling system (RO) aretabulated as followi

In view of the information furnishedsub-condition is considered complied.Complied

by the PP, the stipulated

Quantity of Permeate Recycled in KLy'Month

In view of the compliance reported against each of the sub-conditions, the overall comptiance of the stipulated condition isconsidered complied.COMPLIED

5 Waste stream should be treatedbefore taking into solar evaporationpond, Solvent from effluent to berecovered before discharging intosolar evaporation pond.

Project Proponent vide letter dated 19.09.2018 received inMOEF&CC, RO Bhopal on 25.09.2018 submitted thefollowing:Complied.Company has discontinued Solar Evaporation ponds from August 2007.The correspondence for discontinuation of solar evaporation has beensubmitted to MoEF, New Delhi in August 2007. The copy of letter is

attached as Annexure fs in the main report in the main report inthe main report.We have solvent recovery internally integrated with manufacturingprocess. We have installed primary & secondary condensation. We havesupplied chilled water at primary stage for condensation of solvents &Chilled brine for secondary condensation. We have proper monitoring ofsolvent recovery and we are regularly monitoring generation of VOCs,

Specific Condition No 6.the solvent recovery details have been given in

Annexure 17 in the main report. The generated residues from solventrecovery are sent to Common Hazardous Waste Incineration and LandfillSite - BEIL, Ankleshwar for Incineration. lhe detoiled summorv of

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in the main rePort.ln view of the information furnished by the PP that solar

evaporation system is discontinued and as primary and

secondary condensation of solvents is being done at unit level'

the stipulated sub-condition is considered complied w'r't'

solvent recoverY.

COMPLIED

ingle stage evaporation for treatment

of high COD, low TDS waste water'The Unit has membership of Bharuch

Enviro Infrastructure Ltd (BEIL), Ankleshwar' The aqueous effluent

containinghighCOD,HighTDSissenttoBharuchEnvirolnfrastructureLtd(BEIL) for further treaiment & disposal'The detoiled summorv of

solvents / valuable by products have been recovered from waste streams

generated during production process ' The detailed summorv of solvent

Stage Evaporation System is in operation for High TDS waste'

oet]alts of High rDS effluent sent to BEIL for disposal are attached for the

period January 2018 to June 2018 in Annexure rq in the main report

and the summarized detailsof treatment for high TDS effluent waste

tion svstem is tabulated below:

ln view of the information furnished by the PP, the stiPulated

sub-condition is considered complied'

Complied

in EC Complionce SPectltc

water in evaPoratlo --u'nn ros

"tttuent for evaporation (KL/Month)

Sr. No Month

7 Jan- 2018 214.O

2 Feb - 2018 282.49

3 Mar -2018 1094.51

4 Apr - 2018 1838.s

5 May -2018 1407.081426.36 Jun - 2018

As reflected in EIA / EMP Report,

Company to install forced evaporation

system for aqueous waste to avoid

discharge of effluent into solar

evaporation Pond

ln view of the .otpli"t." t"ported against each of the sub-

conditions, the overall compliance of the stipulated condition is

considered comPlied.

COMPLIED

The Methvl Chloride recoverY

P,"J..tProponentvide|etterdated19.09'2018receivedinMOEF&CC,ROBhopalon25'09'2Ol8submittedthefollowing:Complied.Methvl Chloride Plant is in operation with recovery of 100%'

Company to recover Methyl Chloride

(CH3CI) bY installation of CH3CL

recovery Plant.

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Condition Compliance StatusNo. Description

Recovery in %

Qua ntityRecovered in

MT/Month57 57 136.2 136.8 L63.8 168.6

ln view of the inform;sub-condition is consicComplied

rtion furnished by the PP, the stillered complied.

rulated

Solvent recovery to be improved andattempts to be made to achieve atleast 90 % recovery wherever possible.

We have solvent recovery above 95%. We have sblvent recoveryinternally integrated with manufacturing process. We have installedprimary & secondary condensation. We have supplied chilled water atprimary stage for condensation of solvents.& Chilled brine for secondarycondensation. We have proper monitoring of solvent recovery and we areregularly monitoring generation of VOCs. The solvent recovery detailshave been given in Annexure L7 and the overall solvent recoverv detailsare summarized as below:

Monthly Percent Solvent Recovery DetailsSolvent Jan-18 Feb-18 Mar-18 Apr-18 May-18 J un-18

MethyleneDichloride

95.53No

Production

No

Produ

ction96.72 96.25 96.92

Toluene 97.3LNO

Production

No

Produ

ction97.01 97.1r 97"53

EthyleneDichloride

No

Produ

ction98.9s 99.04 99.09 99.1 qq

HNP 98.01 97.63 97.48 98,15 98.1-5 98.14

MethylChloride

100 100 100 100 100 100

In view of the information furnishedsub-condition is considered complied.Complied

by the PP, the stipulated

Rest solvent which can't be recovered,to be incineration.Action to besubmitted to Ministry within 3 months

The generated residuesHazardous Waste IncinerIncineration.The followin5sent to BEIL, Ankleshwar c

lNl

trom solvent recovery are sent toation and Landfill Site - BEIL, Ankles

1 is the summarized details of incineralrn monthly basis:

:INERABLE WASTE - MT / Mont

Commonhwar for)le waste

MONTHOPENING

STOCK

(MT)

GENERATION DISPOSAL

(Total Sentto BEtL)

cLoslNG

STOCK

ORGANIC&

AQUEOUSJon'78 37.45 79.6 r02.71 1.4.34

Feb'78 t4.34 33.36 33.36 L4.34

Mqr'78 t4.34 80.s 76.81 1-8.03

Apr'78 18.03 1,49.r 1,23.19 43.94

Mov'78 43.94 287 278.3s 52.59Jun'78 52.59 210 231 .54 25.0s

Totol 839.56 8s1.96GPCB Permissible Limit 978 Complit rd.

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e PP, the stiPulated

sub-condition is considered complied'

Complied

IMT/ six

against each of the sub-

conditions, the overall compliance of the stipulated condition is

considered comPlied.

COMPLIED

following:Not Applicable - Company has discontinued operation of Incinerator for

disposal of Hazardous Waste' The correspondence for discontinuation of

lncinerator plant has been submitted to MoEF' New Delhi in March 2005'

The copy of letter submitted to MoEF is attached as Annexure fS in the

main report. The organic waste collected and sent to incineration of

Bharuch Enviro Infrastructure Ltd (BEIL)' Ankleshwar'

ln view of the information furnished by the PP that incineration

is dismantled and as incinerable waste is sent to BEAIL for

incineration, the stipulated sub-condition is considered

complied w.r.t. incineration'

Complied

.t propo*nW''0" tttt"t Oated 19'09'2018 received in

MOEF&CC, RO Bhopal on 25'09'2018 submitted theCotnptnY to uPgrade existing

incinerator for incineration of

hazardous waste. Organic waste, solid

waste generated, to be collected and

incinerated for total destruction'

co-'pri"a.rn"*mpanyh.'providedHazardouswaste5torageareaasper CPCB Guidelines. The photograph showing storage of Hazardous

waste area is attached as Annexure q in the main report of Annexure

25 in the main report (Compliance to Hazardous waste management

rules 2016) The company is a valid member of Bharuch Enviro

lnfrastructure Ltd (BEIL) & ETP Sludge has been sent to TSDF of Bharuch

Enviro Infrastructure Ltd (BEIL), Ankleshwar. The copy of membership of

BEIL is given as Annexure 16 in the main report'

ln view of the information furnished by the PP' the stipulated

sub-condition is considered complied'

Complied

n--r t"tt".t"a in EIA / EMP Report, solid

waste and ash obtained after

incinerator should be stored in plant

premises in a Pit with imPervious

flooring and leachate collection

system.

DETAILS OF I

able waste sent to Bharuch

Enviro Infrastructure Ltd (BEIL), Ankleshwar is attached for the period

January 201g to June 2018 in Annexure -re in the main report.

The waste disposal quantity is summarized in following table

below:

nrh ana sludge from ETP to be finally

disposed off in a TSDF of BEIL'

Leachate to be sent to ETP for

treatment

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Condition Compliance StatusNo. l Description

Feb'78 !4 34 33.36 33.36 t4.34Mor'78 74 34 80.5 76 8r 18 03Apr'78 18.03 149.1 rz5. LJ 43 94May'78 43.94 287 278.35 52.59lun'78 52.59 21,0 237.54 25.05

Totql 839.56 851.96GPCB Permissible

Limit(MT/ Six Months)

978

DE WASTE ,AND

MONTHOp.

Stock

GENERATION in MT/Month Solidwaste

Closing

StockETP

Sludge

Salt(lnorganic

solids)

TotalQuantity

Sentto

BEIL

All Quantities in MTtan'18 34.1r 41. 792 233.00 266,00 1 l-1Feb'18 1lt 32.77 19'J..44 224.2L 224.33 0.99Ma"78 0.99 32.48 193.6s 226.L3 22s.09 2.03Apr'78 2.03 39.00 190.00 229.00 229.00 2.03Mov'78 203 4t.04 194.55 237.62 235.59 2.03Jun'78 2.03 41.5 195 238.48 226.50 11.98

Totol 227.79 LL56.64GPCB Permissible

timit(MTl Six Monthsl

250 TITL

F SOTID W ILLINGTOTAL LANDFILL WASTE DETATLS -All euantities are in MT/Month

MONTH(ETP

SLUDGE +

sALT)*

DCP

SLUDGE*

NON-RECYCLABLE

PLASTIC

WASTE/INSULATI

ON WASTE

TOTAL

Jon'78 zbb 1195.58 27.22 1488.80Feb'18 224.33 283.03 16.40 523,76

Morch'78 225.09 569.79 ZO.UO 820.94Apr'78 229 442.39 23.75 595.L4Moy'18 235.59 440.9I 22.09 698.59June'18 226.50 367.89 26.02 620.47

fotal 1406.51 3299.s9 r4t.54GPCB Permissible

Iimit(MT/ Six Months)

1427 7200 352,5

+All Quontities ore well within GPCB Consented Limits

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Compliance Statuscondition

ruo. I DescriptionOiTnrfS Of OCp SLUDGE (BY-PRODUCT / SOLD As s(JlL LUNUr I rL'rYl

MT/Month - Non Hazardous Waste ' ,

MONTH

l",f 18

OPENING

STOCK

(MT)

GENERATI

oN (Mr)

DTSPATCH (Mr) ClosingStock

PARTY' BEIL

689.06 1195 Jt5,U) 1195.58 363.43

Feb'18 Jb5.45 4ZZ 0 283.03

569.79

502.40

5|J.tOMarch'78 502,40 825 181.85

Aor'78 569.79 510 5 LO.1 442.39 32L.20

Moy'78 32r.20 677.L2 437.75 440.9r 119.66

!une'78 IIY.DO 640 0 367.89 39t.77

Total 4269.t2 1260.85 3299.59

GPCB

(*) Sold as Soil Conditioner to end user: G B AGRO Industri

!723, GIDC, Panoli, Ankleshwar - 394LL6'

ln view of the information furnished by the PP' the st

sub-condition is considered complied'

Complied

:s, Plot no

ipulated

d against each of the sub-

conditions, the overall compliance of the stipulated condition is

considered comPlied.

COMPLIED

8

9

Destruction efficiency of incinerator to

be assessed bY agencY like CPCB and

reported. ComPanY to monitor VOCs

and data submitted to MOEF I CPCB IGPCB regularlY

Project Proponent vide letter datecl 1y'uv'zur6 IeLcrvtru I

MOEF&CC, RO Bhopal on 25'Og'IOLB submitted the

following:Not APPIicable.

Company has discontinued operation of Incinerator since April 2004' The

incinerable waste has been sent to common incineration facility to

Bharuch Enviro lnfrastructure Ltd, Ankleshwar' The Company has valid

membershipofcommonfaci|ityBharuchEnviro|nfrastructureLtd(BEIL)Ankleshwar, The copy of letter submitted to MoEF is attached as

Annexure rs in the main report'|nviewoftheinformationfurnishedbythePPthatincineratoris dismantled, the stipulated condition is considered not

applicable to PP.

COMPLIANCE NOT APPLICABLE TO PP

As oer CREP, bio assaY test to be

replaced bY ToxicitY Factor Test

'Method develoPed bY CPCB' Tr=4 to

be achieved bY December 2003 and

Tr=2 bY JulY 2005. Action Plan to be

submitted within 3 months

Project Proponent vide letter-dated'19'uv'zu-t6 IeLcrvtru rl

MOEF&CC, RO Bhopal on 25'09'2018 submitted the

following:

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Condition Compliance StatusNo Description

by NCT for further treatment & deep sea disposal through pipeline. Thetreated effluent analysis reports for January 2018 to June 201g attachedas Annexure 13.TF factor monitoring results are attached for the period of January 201g

to lune 2018 in Annexure -13 A in the main report & photograph

showing TF Test implementation is attached as Annexure 13 B in themain reoort.The summarized toxicity factor results are tabulated as below:

Month Achieved Toxicity FactorJanuarv 2018 2

Februarv 2018 2

March 2018 2

April2018 zMav 2018 2

June 20L8 2

The CREP report nas been updated attached as Annexure fS in therepOrt. The summary of CREP is given below

Total no of Points in CREP Total No of Complied Points asper CREP

10 10

ln view of the information furnishedcondition is considered complied.COMPTIED

by the PP, the stipulated

main

10 Green belt in 0.2 hectors in addition to3.66 hector to be provided to mitigatethe effect of fugitive emissions in theplant. Development of green beltalong the boundary wall, open spaceand avenue roads to be improved inconsultation with local DFO as perCPCB guidelines

Project Proponent vide letter dated 19.09.2018 received inMOEF&CC, RO Bhopal on 25.09,20 j.8 submitted thefollowing:CompliedToral - 687 Nos.oftrees have been planted during period January 2o1g toJune 2018.

The unit was established in 1980-81 at notified industrial estate, GIDC,Ankleshwar. Till date 3.86Hector of factory area is developed as greenbelt as per cPCB Guidelines.The Map showing existing green belt area isattached as Map 1 & Photographs showing existing green belt is enclosedas Plate 1.The company has developed in house nursery since i.993-94and donates 1000-2000 no of saplings without charges to surroundinga rea.The unit has obtained permission from NHAI for development of greenbelt near NH-8 passing adjacentto Unit for 1g00 sq M Area. The unit hasapproached Western Railway division for additional 70OO So M arealocated adjacent to northern boundary to company for conversion of railsidings to green belt. The copy of NHAI permission & Railway Lano

Request letter is attached as Annexure 20 A & 20 B in the mainreport.Existing Green BeltArea in Ha

Proposed AdditionalArea To be coveredunder green Belt inHa

Total Area undergreen belt in Ha afterproposed green belt

4.51L a.es I o.os

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ComPliance Status

e stiPulated

condition is considered complied'

.2018 received in

submitted the

following:ComPlied.The unit has sPecial team like MaxP

resource reduction and recoverY i

waste conversion to valuable P

following Cleaner Production t

technologies. .. -L-i-- i1 ChloridetJ itt Plant - Mother liou.3r,':":1i:,^t.1

(NH4C|), company tl" in't'rttO nTt:lf ,: :ltr;;liH;:';'il' HiJ'';;['rH.cL) is treated in,.^"""-"'-'----erv plant

and converteo in to''uurr-Jle products like Ammonia' CaClu& Di

Itlrt Phosphate (DCP sludge) as a Fertilizer'

zf rt."."."u/-o*,ttoyiin "il'''i"^ genera-tes^ Mix Liquor containing L0

% sodium ,rtpn'ttx'-*;;;il hal installed MEE for recoverv of pure

sodium sulPhates'

3) Monocrotophos Plant: Generates MethylChloride gas & company nas

installed Methyl Cftro'ia" '"lovery

plant & recovered Methyl Chloride

has been sold as bY Product'

4) The company f'a' in'tall"d 1OO KLD RO System & permeate is recycled

back as cooling tower water makeup' ^,^r !.^-1, r^ hniler {s0-50bacK as coorrrrE '"*'' ^"'^":: :^;;";.'tt recvcled back to boiler (50-60

5) The generated boiler steam condensate recY(

% condensate recoverYl

gt Jnit has provided economizer at boiler for heat recovery'

7) lmplementation ot non-chemical treatment in cooling towers to

reduce blow down bY 20%'

8) Bio Degradable *"i" - Company has installed captive Bio Gas Plant

& organic .otpo"-yt'd foi conversion of food waste to organlc

," ,1".1,'ii,he information furnished by the'PP' the stipulated

londition is considered complied'

COMPLIED

te minimizationtechniques to

reduce pollution load and action plan

to be submitted to Ministry within 3

months

09.2018 received in

18 submitted the

following:

ff llX;t;.' i m pl e m e nted rai n w ate r h a rvesti ng-at l1T:^?: I :':?1"',;"

House and R&D Buildings;' p"t tttion plan submitted to MoEF & CC' The

total 250 Sq M Roof r;;;;tt is covered. under rain water harvesting

scheme. The average annual harvested water quantity is 325 KL which is

stored in temporary srorage & used in gardening/flushing' The copy of

action plan submitted is attached as Annexure 21 in the main report'

The details of rain water harvesting implemented is attached as Annexure

zz in the maiqlg-Perl

take rain water

as Per action Plan

submitted to MinistrY

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In view of the information furnishedcondition is considered complied.COMPTIED

by the PP, the stipulated

Company to comply withEnvironmental Protection measuresand safeguards recommended in EIA /EMA / RRA reports as well asrecommendations of public Hearingpanel

Project Proponent vide letter dated 19.09.2018 received inMOEF&CC, RO Bhopal on 25,09.201.8 submitted thefollowing:Complied.The Summarized EMp a!q_.lm!]qnentation status is given below.

Air Pollution ControlFlue Gas & ProcessVents

Use of Clean Fuel: The unit has providedNatural Gas/FO Based boilers ad hot airgenerators with adequate stack height fordispersion of pollutantsProcess Emissions: The unit has provided HCl,Caustic +Water scrubbers for control ofprocess emissions. The unit has also providedbag filters for handling of particulate matteremissions.

Air Pollution ControlFugitive EmissionControl

The unit has provided seal less pumps, closedtransfer of materials with pneumaticpressure, solvents, minimization in manualhandling, implementation of LDARProgramme f or minimization of fugitiveemrsstons.

Water PollutionControl

The unit has provided 450 KLD Capacity of ETpwith primary, secondary & tertiary treatmentcapacity. The treated water is sent to FETpOperated by NCT, Ankleshwar for furthertreatment and deep sea disposal throughclosed pipeline.

Noise PollutionControl

The Unit has provided acoustic enclosures.preventive maintenance, to high noisegenerating machinery. The employees areprovided Ear plug, ear muff for prevention ofnoise, The green belt developed to curtainambient aii noise leVels.

Waste Management The unit has obtained membership of TSDF -BEIL Ankleshwar for disposal of Hazardouswaste. The by products have been sold toauthorized end user based on applicability ofHWM Rules 2016.

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ComPliance Status

' the stiPulated

condition is considered complied'

COMPLIED

Water Management

environmentalNoise, Fugitive

emissions, VOCs, Daily ettluent analysis are

""-g"irrg at internal laboratory of UPL Unit 1

., ir"ff it conducted by Third Party - NABL

Accredited laboratorY'

The unit has installed continuous onltne

r.1". ,t treated effluent for parameters pH'

ioi, aoo, BoD, TSS, AN& Flow as Per cPcB

EnvironmentalMonitoring

onductedbY GPCB

for Each Financial Year tor tnvlronmental

Audit of all parameters' The auditor submits

audit repot"t with recommendation to GPCB

EnvironmentalAuditing

emented rain water

tration buildings' Boiler

house and LaboratorY building'

Rain Water

Harvesting

green belt

age of 33402e teen Belt

DeveloPment

fledged environmentplace- for

.*"Po1,,1i1Auditing & Monitoring of Environmentat

EnvironmentalManagement Cell

Project ProPonent vide letter a.t.O.t.O fg.09.2018 received in

MOEF&CC, RO BhoPal on 25.09.2018 submitted the

The unit is oPerated as GPCB Consent le i!er9I9

Co.pt"v to-ot"p*V to .ahere to stipulations

made bY GPCB

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with amendment vide GPCB CC&A # H

to 12.05.2018 (The copy ofvarid cc& A is attached as Annexure-1B).The consent conditions are reviewed and certified by Schedule r. Auditorappointed by GpCB by regular monitoring and preparation ofenvironmental audit report as per GpcB Format and submission to GpcBon annual basis. The copy of consent compriance (Adequacy) is attacheoas Annexure zS in the main report.The unit submits various Reports / Returns to GpCB on time.In view of the information furnished by the pp, the stipulatedcondition is considered complied"COMPLIED

No further expansion / modificationsin the plant to be carried out withoutprior approval of MOEF.In case of deviations / alterations inthe project proposals from thosesubmitted, a fresh reference to bemade to Ministry to assess adequacyof conditions imposed and addadditional environmental protectionmeasures required, if any

Project Proponent vide letter dated 19.09.201g received inMOEF&CC, RO Bhopal on 25.09.20j.9 submitted thefollowing:Complied

d CCA amendmenated as per GPCB

ent for existing proide GPCB CC&A # 8

12.05.2018 (The copy of valid CC& A is attached asnit has applied to GPCB for Renewal of Consent& A R&A/18 dated March 30,2018. (The copy of

consent renewal submission acknowledgement is attached as Annexure1C).

The unit has applied to MoEF&cc for Environmental clearance forproposed expansion of pesticides & Intermediate products in Month ofDecember 2017.

PP submitted that Environmental Clearance #J.7L071'/407/2006-tA.| (t) dated 04.04.2007 granted to Unit #l was for product mix change and the sane was not

d and not obtained NOC (CTE), However,urnished by the pp, several product mix cmade over the years w.r.t. Environ

Clearance # J.1IO1.I/77/2OOZ1A.n dated 17.07,2003 inaccordance with the guidelines available under ErAnotification 2004 w.r.t, product mix change under noincrease in pollution load with prior permission from GpcB.The said product mix changes are valid.w.r.t. EIA notificationOM dated 28.77.2016 related to product mix change and asthe PP has intimated the said changes regularly in the form ofSix-monthly compliance reports, Ministry may take anappropriate view on the applicability of said OMretrospectively taking into consideration the dynamics of thepesticide sector.COMPLIED SUBJECT TO ACCEPTANCE By MOEFCC, New Dethi

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following:ComPlied.The comPanY is comPlYing to MSIH

Rules requirements' The c

onsite emergencY Plan i

hazardous chemicals as Per

2000 is attached as Annexure za in the main report & summartzeo

9.2018 received in

MOEF&CC, RO Bhopal on 25'09'2018 submitted the

The list of approvals obtained from Chief lnspector of Factories' Chief

Inspector of Explosives, Fire Safety lnspectorate etc are given in Annexure

below. --.-----_-Tot.l ttlo of s..,b Rules under

MSIHC Rules 2000 -Total

No of sub Rules

under MSTHC Rules 2000

comPlied bY Unit

5r. No

201

eohave been comPli

oft & Summarized below

ln view of the inforn Uf, tf* PP, the stiPula

condition is considered complied'

COMPLIED

wtateri a I/Descri Ption VatiditYLicense No.

MethYl Chloride Tonner storage 3010912022GIHO/GJl06l282\G1441)

3010912022GlHolGJlosl294(Gt44r)

Methvl Chloride (filling Point)

30l09l2or8- ApPlied for

renewalGlHOlGJlos/294

(G1441)MethYl Chloride (HYdro testing)

3rltzl20t9PlHQlGJltsltooz(P1.0ss5)

Ethanol Methanol Toluene

3Ol09l2o2oslHolGJl03lLLTlsL2r2)

Anhydrous Ammonla 5l -r 6{

ST-2

nr,tlydrout Ammonia ST-3 &

ST-43uoelzo2oslHolGJl03l2oz

(s13se)

3tltzl20t9Pl1alGJlrslrozs/(P10s7e) _

Furnace Oil

3tl12l2ot9PHAJGJITSI!377(P10839)

HSD

3010s1202LclwclGJl06/8st(G14084)

Chlorine

TFAC Gas 30l09l2o2rclwclGJl06lseL(G14084)

Ammonia Gas CYlinders 30losl2o2oclwclGJl06lt663(G28218)

ted

th MSIHC Rules

vals of Chief

lnspector of Factories, Chief Inspector

of Explosives, Fire Safety Inspectorate

etc, to be obtained

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Condition Compliance StatusNo,l Description4 Company to comply with HWM Rules

and authorization from GpCB to beobtained

Project Proponent vide letter dated 19.09.2019 received inMOEF&CC, RO Bhopal on 25.O9.2O1.g submitted thefollowing:CompliedThe company has implemented Hazardous waste coilection, storage anddisposal system as per applicability of HWM Rules 2016. The unit hasobtainedGPCB Consent to operate (cc&A) vide GpcB cc&A # 88493dated 26.09.2017 valid up to 12.05.2018 (The copy of valid cc& A is

attached as Annexure-r e in the main report). The Unit has applied toGPCB for Renewal of consent vide letter no u1/cC & A R&A/1g datedMarch 30,2018. (The copy of application for consent renewal submissionacknowledgement is attached asAnnexure f C in the main report),The detailed compliance to The Hazardous and other waste(Management & Transboundary Movement) rures 2016 is attached as

Annexure ZS in the main report & summarized below.Sr.

No

Total No of Sub Rules underHazardous & Other Wastes

(Management andTransboundary Movement)

Rules 2016

Total No of Sub Rules underHazardous & Other Wastes

(Management andTransboundary Movement)Rules 2016 complied by Unit

1 24 24In view of the information furnishedcondition is considered complied.COMPLIED

by the PP, the stipulated

5 Overall noise levels in and aroundplant area to be kept within thestandards (85 dBA) by providing noisecontrol measures including acoustichoods, silencers, enclosures etc, on allsources of noise generation.

Project Proponent vide letter dated 19.09.2019 received inMOEF&CC, RO Bhopal on 25.Og,20Lg submitted thefollowing:Complied.

and earmuffs to workers working near Boiler & compressor area.

In view of the information furnished by the pp, the stipulatedsub-condition is considered complied.Complied

Ambient noise levels to conform tostandards i.e. 75 dBA (day time) and70 dBA (night time)

AmbientThe mon

Noise

itorinrlevel in the unit conforms to the stipulated standards.

monitoring ranges are given as below.

MonthMn Max Mn Max

Day time - GPCB

Limit 75 dBANight time - GPCB

Limit 70 dBAJan-18 f+.5 73.7 51.9 67.4Feb-18 59 72.8 51.4 67.8Mar-18 )v 73,7 52.L o t.zApr-18 58.1 73.2 52.1 69.1Mav-18 .+o, I 64.1. 42,5 64.9J un-18 55.2 73,4 48 ot.r

The monitoring resu lts of Ambient Noise level at different location

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8 to June 2018 in

Annexure -zs in the main report'

ln view of the information furnished by the PP' the stipulated

sub-condition is considered complied'

Complied

each of the sub-

conditions, the overall compliance of the stipulated condition is

considered comPlied'

COMPLIED

following:

;: checkup of each employee has been conducted for

57 during ianuary 2O!8 to June 2018 for Physical

Ex moglobin, CBC' ESR' ECG' Complete ine Examination'

Lever Function, Kidney i'nAion' Creatine' Blood Sug X Ray for Chest'

sonography etc. The "tpt" topy of Medical Report has been attached as

9.2018 received in

MOEF&CC, RO Bhopal on 25'09'2018 submitted the

Annexure 28 in the main report'

Pre-employment medical checkup was done

oeriod of January 2018 to June 2018'

The unit has provided in-plant clinic facility with resident doctor' The in-

plant clinic is facilitated-*iin ttt"'t medical equipment' antidots and

essential medicines. The Medical record of all employees has been

maintained and reviewed annually'

ln view of the information furnished by the PP' the stipulated

condition is considered complied'

COMPLIED

for all new joiners for the

e*eicise for all employees, specifically

for those engaged in handling

hazardous substances'

OArp"'t".1 health surveillance

program to be undertaken as t:iu',lt

First aid facilities in OHC to be

strengthened and medical records of

each emPloYees to be maintained

d 19'09'2018 received in

,VOEFACC, *O Bhopal on 25'09'20L8 submitted the

following:Complied.The UPL Unit#l is ISO 9001,1SO 14001 & OHSAS 18001 Certified companY'

The UpL has estab[shed separate Environment Management cell with full

fledged laboratory for different types o ng' The ry has

facility for Water, Stack Monitoring' y Test' Test'

Ambient Air Monitoring, VOC monitor Waste Noise

Level Monitoring Workplace Monitorin ucture nment

Management Cell is given as Annexure lf in the main report

n r"o-r..tJgnviron ment Management

Cell with full-fledged laboratory to be

set up to carry out the environmental

management and monitoring functions

g.Iech, tvl 'Tech. and Ph D inGlobal VP

Environment &

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Compliance Status

ln view of the information furnishedcondition is considered complied.COMPLIED

by the PP, the stipulated

BE. Chemical Engg, Masterin Ecology & EnvironmentScience, Diploma in Safety,EnerRV Manaeer from BEE

Mr. R S Tiwari Sr. ManagerEnvironment

MSc In Organic Chemistry& Diploma in IndustrialSafety

Mr. Purvesh Soni BE Civil, M.E

Environmental Engg.Ms. Kshipra Dave MSc in Chemistry

Ms. Trupti Joshi ExecutiveEnviron ment

B.Tech. Environmental

Ms. Shreya Kundu B.Tech. EnvironmentalScience & Techno

Company to provide adequate fundsfor recurring and non-recurringexpenses to implement the conditionsstipulated by MOEF as well as state

implementation schedule for allconditions stipulated. The fundsshould not be diverted for any otherpurposes

Project Proponent vide letter dated i_9,09.20j_8 received inMOEF&CC, RO Bhopal on 25.09.2018 submitted thefollowing:Complied.The funds are already provided as part of manufacturing activities andoperation of ETP and disposal of Hazardous / Non Hazardous wastes"separate cost codes are also available, The environmental prevention andprotection expenditures incurred during period 2019-19 (yTD - June2018) is Rs.7.13 Lakhs/Day for waste water treatment, air pollutioncontrol, environment management cell and green belt development. Theyear wise details of environmental itures are tabulated below.

EffluentTreatment &

Waste DisposalCost in Rs.

l-akhs

Green BeltDevelopment &

Maintenance Cost

in Rs. Lakhs

Expenses forEnvironmentManagement

Cell in Rs.

Lakhs

113.01

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the PP, the stiPulated

22t.63

ated 19.09'2018 received in

MOEF&CC, RO Bhopal on 25'09'2018 submitted the

following:Complied'The project has been implemented with environmental action plan' Half

yearly compliance reports are being sent during February and August

every year to Ministry of Environment and Forests Regional Office'

Western Region, Bhopal. The detailed summary of submissions is given

condition is considered complied'

plian.MC Bhopal office Details for

UPL Unit 1 Submission Dates

UPr Ur Letter dated 30/1/18Julv 17 To Dec 17

upL ur Letter dated 0218/17Jan 17 To June 17

r-ru ur Letter dated 21lu17Julv 16 To Dec 16

U+ Uf Letter dated 1218/16Jan 16ToJune 16

trpL ur Letter dated 08/2/1615 To Dec 15

UPL Ur Letter dated 03/8/15Jan 15 To June 15

he PP' the stiPulated

lmpl.-".tttt" of the Project and

Environmental Action Plan to be

monitored by MOEF, Regional Office at

Bhopal, GPCB / CPCB. A six monthlY

compliance report to be submitted to

monitoring agencies

ated 19'09'2018 received in

MOEF&CC, RO Bhopal on 25'09'2018 submitted the

following:

to MoEF is attached as Annexure zz in the main report'

ln view of the information furnished by the PP' the stipulated

condition is considered complied'

-ornoanornyany to inform that public that

project has been accorded

Environmental Clearance by Ministry

and coPies are available with GPCB

and mav be seen at MOEF web site'

This should be advertised within 7

days in two local rrewsPaPers and

cooies to be submitted to RO- GPCB'

Project ProPonent vide letter dated 19.09.2018 received in

25.09.2018 submitted theMOEF&CC, RO BhoPal on

following:Complied.

as Ministry, date of financial closure

and final approval of the project by

concerned authorities and date of

commencing the land OgYlggglg$

Iomp.rWo inform Ro-GPcB as well

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Condition Compliance StatusNo. Description

work, if any Financial Closure Date :

The unit has not taken any loan from Bank oR Financial Institute as thecapital investment adjusted internally. Hence Financial closure is notapplicable.

Final Approval Details : The project has received following approvalsfrom GPCB.

= consent ToEstabtish (Noc) # pclNoc/BRcH_2237 [37(8)] dated29.05.2002 aga i nst Envi ron menta I Clea ra nce Appli cation.

= cc&A amendment No 4553 dated !7 /12/2004 from GpcB against theEnvironmental Clearance

Date of Land Development WorkThe Project is located within existing plant in notified industrial estareGIDC, hence no new land has been acquired hence land developmenrwork is not applicable.The unit has submitted communication on above information to Resionaroffice of MoEF Bhopal on 6th June 201g. The copy of same t"t"t"i,,attached as Annexure 32 in the main report.In view of the information furnished by the pp, the stipulatedcondition is considered complied.COMPTIED

Ministry may revoke or suspend theclearance, if implementation of any ofthe conditions is not satisfactory

Project Proponent vide letter dated 19,09.2019 received inMOEF&CC, RO Bhopal on 25.09.20L8 submitted thefollowing:NotedPP stated that the stipulated condition is noted for compliance.NOTED

Ministry reserves the right to stipulateadditional conditions if required.Company, in a time bound manner.will implement the same

Project Proponent vide letter dated 19.09.201g received inMOEF&CC, RO Bhopal on 25.09.201_8 submitted thefollowing:NotedPP stated that the stipulated condition is noted for compliance.NOTED

The above conditions will be enforcedinter-alia under provisions of variousacts and rules

Project Proponent vide letter dated 19.09.2019 received inMOEF&CC, RO Bhopal on 25.O9.2OI8 submitted thefollowing:NotedPP stated that the stipulated condition is noted for compliance.NOTED

Summary note:

i. lmplementation of Conditions:

Out of 27 total conditions, it may be seen that 22 are fully complied, L is compliedsubject to acceptance by MoEFCC, New Delhi, 1 is compliance not applicable to pp and 3are noted' These have been explained in the foregoing compliance report against each

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of the conditions, and the PP needs to take necessary

compliance in respect of the relevant conditions

mentioned below.

ii. General Observations:

a.PPsubmittedthatEnvironmentaIC|earance#J,tLo7tl4o7/2006-lA.l|(|)dated04'o4,2oo7 granted to Unit + r *., for product mix change and the sane WaS not

implementedandnotobtainedNoc(cTE).However,asperthedetai|sfurnishedbythe pp, several product ri* .h.nges have been made over the years w'r't'

Environmental clearance # J.1101lvltlzooz-1A.il dated L7'o7.2003 in accordance

withtheguide|inesavai|ab|eunderElAnotification2004w'r.t.productmixchangeunder no increase in pollution load with prior permission from GPcB' The said

productmixchangesareva|idw.r.t.E|AnotificationoMdated2S'L1,.2}I6re|atedtoproduct mix change and as the PP has intimated the said changes regularly in the

form of six-monthly compliance reports, Ministry may take an appropriate view on

the said Product-mix change'

b.lnreptytooclarifi:otionsoughtvidee-maildated08.10.2018w.r,t'freshwaterconsumption in excess of ,t'iiuiotrd Iimit, PP vide e-mail doted 1L"10'2018 submitted

'n" f:"":;:nn

water consumption as per Environmental clearonce dated 17"07'2003 is

951 KLD,

WehoveapptiedtoGPCBforCTE/Nocforsolid/tiquidpesticideformulation'proaiurit o,i tt/lo/2072 for which EC is not applicable'

GPCBhasgivenpermissionandtheseproductswereincludedinourcC&AcC& A No AWH - 55992 dated 31'07'2013'

AccordinglyfresnwaterconsumptionhasincreasedbySsKLDi'e,total(951+88) 1039 KLD.

According|y,GPCBhasissuedCC&ANoAWH_55gg2dated37.07.2073givingthe details of woter consumPtion'

c.tnreplytoaclarificotionsoughtvidee-moildated08.10.2018w.r.t.hozardouswostegeneration in excess of stipuloted limit' PP vide e-moil doted 11'10'2018 submitted o

detoitedjustificotion,thedetoilsofwhichisenclosedasAnnexure-AA.|nliqhtofthejustification(i.e.,additionofform,ulationuni't+pro-environmentmeosures),MoEFCC,New Delhi moy considq or'i^'ndment in the hazordous woste generation from the

unit during the exponsion proposol'

and time bound action for earlY

and the general observations

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l|l Court Cases and show cause/closure notices:

Project Proponent vide letter dated 28.04.20Lg received in MoEF&cc, Ro Bhopal on07'05'2018 submitted that there are no court case pending against the'prolect and noshow cause /closure notices have been issued by GpcB over the past 3 years.

6*vc-cfu(Dr. H.V.C.Chary Guhtupaili)

Joint Director/Scientist-D

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JustificationforincreaseinHazardousWasteQuantityforUPLUnitlThe upL unit # 1is pre existing unit since 19,7g-79.The unit has obtained environmental clearance

rrom Ministrv or Environment & Forest #;":f:::*::*f: 't::!?2'::l;lir'Ll:1'1tJliil::from Ministrv of Environment & Forest ":T::;;;;;;;;;;ties. rhe EC granted Hazardous Waste

for addition of new pesticides with existing prod tction capacltles' I tre tru Eir q'rvv

Qu a ntiti e s a rgd 4qll9q3$9199

f) Discontinuation of

-"l.ttrr.p*ation

(As per EC condition No 05), The unit has to install

solar evaPoration

advancements in

discontinued solar

ponds for High TDS Stream Treatment

technology, the unit has installed single

evaporation, this has leaded increase in

but looking for oPerabilitY and

stage evaPoration sYstem and

generation of Hazardous Waste

(Solid Salt).

2\ Discontinuation of Incinerator (As per EC

lncineration system for High COD / High

and revised guidelines of CPCB for Inci

incineration system & taken membershi

Bharuch Enviro lnfrastructure Limited (BEIL) Ankleshwar. The 100% lncinerable waste is sent

to BE'L Ankleshwar TSDF Site for disposar. This action has readed increase in generation of

Hazardous Waste (Aqueous Effluent)'

are given below.

Justification for increase in hazardous waste

Consented

Quantity Till date

Qu-dntitY of Hazardous Waste

as Per EnvironmentalClearance letter

t#tLotL I tt7 | 2OO2.l A'tl date d

t717l2oo3

Hazardous Waste CategorY as Per

Environmental Clearance letter

t#LLoLL I tL7 I 2OO2't A'tl dated

Lt17l2oo342 MT/Month

30 MT / Month

4.s Mr / Mo4!lrrcinerator Asl",a!9 107.2 MT/Month

75.6 MT / Monthl*tg*'" Solids from

MonocrotoPhos Plant 183.7 MT/Month82 Mr / Mo4!

Solid Salts 11-.5 MT/MonthNo Mention of Quantities

Salt from RO SYstem

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7.

2.

ETP waste (sludee):our unit is pesticide industry and consists of high toxic effluent. Thus,we are rising primary treatment pH till 10.5 instead of 8.5 which increase lime consumptionand increase in sludge quantity.salt from evaporation svstem: we have incorporated cEpl Action plan at our unit. we aresegregating high TDS Effluent which goes to ETP plant. For high TDS effluent we haveprovided single stage evaporation system for Monocrotophos and other process andgenerated salt sending to BEIL for Landfilling.

Due to increase in quantity of formulationproducts, there'will be increase in Process Residue from pesticide plant (organic)

quantity of Di-calcium phosphate srudge due to conversionWe are increasing generationof ammonium chloride LOO%

internally.

3.

It is converted into valuable By-product like Di-calcium phosphate sludge.100% conversion is due to cEPl action plan implementation in Ankleshwar. Before actionplan about 50% of Ammonium chloride is sold to end-users as permitted in cc&A.

5.

formulation products,waste/PPE's.

waste/rnsularron waste/ppE's:Due to increase in quantity ofthere will be increase inNon-Recyclable plastic waste/lnsulation

5' Due to increase in quantity of formulationproducts, there will be increase inDate expired -/ott specification product.qWe have incorporated

cEPl Action Plan at our unit. we are segregating high TDS Effluent *hi.t goes to ETp plant.

f:l l''l t"xic &. coD_effluent-and Due to increase in quantity of formulation products, therer Increase In quantity of tormulation producwill b increase inAq Effluent from drums washing / Reactor washing / tank washing.

The summarized quantities with justification of increase in quantities of Hazardous wastes istabulated below for your ready reference.

s

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uan

fiiffi orl rr'l roRMUtArloNsin Y€AR 2016

.-aoontouorronvulATloNPRoDucrsin

Year 2013

Total QuantitY AfterExpanslons bsed on

EnvironmentalClearance letter

l#lrorrl r17 lzo02.lA.ll dated17 17 l2oo3

srN

o

TyPe of Waste

Exlsting

quantity inMT/Year

Addltional

quantity for

[ormulatlon

product

ITotal I

quantit I

y after I

proposed

formulatlon

p roduct

ExistingQuantltY

as perFormu latlon CTE No

I szsoo

I Applicatio

lnt

AddltionalQuantitY

as perFormulation CTE No

52 500

I Appllcatlo

lnI

I

FinalQuantitY

afteraddltion of

FormulatlonProducts

(GPCB CC & A

NO AWH55992 dated3r17 lzor3)

Method ofDisposal

360MT/YR

360MT/Y

R

200MT/YR

500MT/YR

Disposat atBEIL TSDF

(Land filling360MT/Y R

360MT/YR

360MT/YR

NIL

1ETP Waste

ISludge)

360MT/Yr

1704MT/Yr

500MT/YR

2,20+MT/YR

Disposal at

BEIL TSDF(Land fillingl770+

MT/Yr

t70+MT/Yr

NL170+MT/Yt

2

Salt fromEva po ratio n

System

720MT/Yr

984MT/Yr

\z6LMT/Yr

7267MT/Yr

25MT/Yr

1286MT/YR

Disposal to

BEIL forCommon

lnc i ne rator1061

MT/Yr

1 061MT/Yr

MT/YrAddition

due toFormulatio

n

3

Process

Residue frompesticide Plan

(Organ ic.)

7++MT/Yr

9t7MT/Yr

NL11

MT/YR

Disposal to

BEIL forCotnmon

I nci ne rator11

MT/Yr

11

MT/YrNL

11

MT/Yr

11

MT/Y

4Eva po rati o n

system Salt

11

MT/YrNL

138MT/YR

138MT/Y

R

NL138

MT/YR

Disposal to

BEIL TSDF

(Land fillinglNL

138 MT/Annum -

Due To Installation of

RO As Per EC SPecinc

Condition No 4

138MT/YR

NLRO

Rejects(AfterEvaPorationJ

NL

7200MT/Y

R

7,200MT/YR

14400MT/Y R

Sale to actual

end user as a

fertilizer OR

DisPosal at

BEILTSDFll,and filling)

7200MT/YR

?200MT/YR

NL

15 MT/Yr -

Additio n

Due to

Formulation

7200MT/YR

6

N H4CLTreatlne lltSludge (Di -calci u nt

Phosphateslu dee l

12000MT/Yr

NL

IJ

MT/Yr

IJ

MT/YR

250MT/YR -Addition

due to

Fo rmulation

Expansion

265MT/YR

send to BEll-

,A nkleshwarfor

Landfill i ng7

Non-Recyclab le

plastlcwaste/lnsulation

waste /P P E's

NL NL NL NIL

15 MT/Yr -

AdditionDue to

Formu lation

15 MT/YrIJ

MT/YR

5

MT/YR

20MT/YR

send to BEILfor

I nci ne ratio n

NL NL NLB

Date exPlreo -loflspec ificationprod uct

NL

450KL/YR

220KL/YR

670KL/YR

Send to BEILfor

I nci nerationNL NL

450 KL/Yr- Addition

due toFormulatio

450KL/Yr

9

Date exPired -/0ffspecificationprod u ct

NL NL

lncreose'Releretlce

Refl-CC&A

Amendment No 781

Ref2 - EC LetterI# 1 1017 /117 /20

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